In Neil Patullo v HMRC [2014] UKFTT 841 (26 August 2014) the FTT dismissed an appeal concerning tax planning arrangements involving the surrender of second hand life insurance policies similar to those implemented in Drummond [2009] STC 2206.
The first issue concerned the validity of a discovery assessment issued in relation to the taxpayer’s 2003/04 return.
Firstly the taxpayer contended that there had been no discovery within the meaning of TMA 1970 s 29(1). Although HMRC had been investigating similar schemes since 2005 the FTT found that the turning point was the release of the Court of Appeal’s decision in Drummond in June 2009 endorsed by the refusal to give permission to appeal to the Supreme Court in November 2009. At that stage ‘what may have been a suspicion even a strong suspicion was converted to the...
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In Neil Patullo v HMRC [2014] UKFTT 841 (26 August 2014) the FTT dismissed an appeal concerning tax planning arrangements involving the surrender of second hand life insurance policies similar to those implemented in Drummond [2009] STC 2206.
The first issue concerned the validity of a discovery assessment issued in relation to the taxpayer’s 2003/04 return.
Firstly the taxpayer contended that there had been no discovery within the meaning of TMA 1970 s 29(1). Although HMRC had been investigating similar schemes since 2005 the FTT found that the turning point was the release of the Court of Appeal’s decision in Drummond in June 2009 endorsed by the refusal to give permission to appeal to the Supreme Court in November 2009. At that stage ‘what may have been a suspicion even a strong suspicion was converted to the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
